URGENT/ACTION REQUESTED
[14525]
March 12, 2002
TO: MONEY LAUNDERING RULES WORKING GROUP No. 13-02
RE: DRAFT COMMENT LETTER ON NASD ANTI-MONEY LAUNDERING
COMPLIANCE PROGRAM RULE
We recently sent you a Securities and Exchange Commission request for comment on
proposed NASD Rule 3011, which would prescribe minimum standards for anti-money
laundering compliance programs established by NASD members under the USA PATRIOT Act
(“Act”).1 Attached for your review is a draft of the Institute’s comment letter on the proposal.
The draft letter recommends that the rule provide an exemption for broker-dealers who
underwrite securities issued by registered investment companies that have established an anti-
money laundering program meeting the requirements of Section 352 of the Act. In support of
this proposal, the letter explains that it would avoid both unnecessary regulatory duplication
and the creation of a bifurcated compliance examination regime – without creating any gaps in
anti-money laundering compliance.
Comments on the proposed rule are due by March 18th. If you have any comments on
the attached draft letter, please contact me at (202) 326-5822 (email: frances@ici.org), or Bob
Grohowski at (202) 371-5430 (email: rcg@ici.org) by noon on Friday, March 15th.
Frances M. Stadler
Deputy Senior Counsel
Attachment (in .pdf format)
1 See Memorandum to Money Laundering Rules Working Group No. 9-02, dated February 28, 2002.